Case Summary (G.R. No. 180915)
Summary of Events
On the night of September 22, 2001, the appellant engaged in a drinking spree with the victim and others. Early the next morning, the victim was stabbed by the appellant after a sudden confrontation outside the victim's home. Eyewitness Jericho Capanas, who witnessed the attack from close range, provided critical testimony regarding the events leading to the murder. The appellant was arrested shortly after the stabbing, found at the scene with a bloodied weapon, and was later identified by the victim before he succumbed to his injuries.
Trial Proceedings and Evidence
The trial court found the prosecution's case credible, based largely on eyewitness accounts and forensic evidence provided by Dr. Romeo Salen, the medico-legal officer. Dr. Salen testified that the victim suffered two stab wounds, with the wound to the chest being fatal. The appellant presented a conflicting account, claiming self-defense during a scuffle over a weapon, but his narrative was undermined by the evidence of premeditated malice.
Credibility of Witness Testimony
The appellant challenged the credibility of the eyewitness, Jericho Capanas, asserting inconsistencies in his testimony. However, the court found such discrepancies minor and did not impact the overall reliability of Capanas’s account, which was supported by physical evidence. The trial court determined that Capanas had no motive to fabricate his testimony and that the prosecution had clearly proven the appellant's guilt beyond a reasonable doubt.
Admission of Guilt
The court noted the appellant's own admissions, both in a letter to the victim's brother asking for forgiveness and during his testimony, where he acknowledged causing the victim’s death. This led to strong implications of guilt, with the court interpreting these admissions as corroborative evidence of the appellant's culpability in the crime.
Application of Treachery
The court affirmed the presence of treachery in the commission of the murder, asserting that the attack on the victim, who was unprepared and vulnerable after being roused from sleep, amounted to a swift and unexpected assault. The victim's intoxication further inhibited his ability to defend himself, substantiating the court's finding of treachery that qualified the murder.
Damages Awarded
The RTC originally ordered the appellant to pay P50,000 in civil indemnity and moral damages. Upon review, the Court of Appeals increased the monetary awards and imposed addi
...continue readingCase Syllabus (G.R. No. 180915)
Case Overview
- Case Citation: 641 Phil. 503
- Jurisdiction: First Division
- Date: August 09, 2010
- Parties: People of the Philippines (Plaintiff-Appellee) vs. Charlie Nazareno y Melanios (Accused-Appellant)
- Nature of the Case: Murder
Charges and Arraignment
- Charge: Charlie Nazareno y Melanios was charged with murder under the information that he willfully and feloniously attacked Romeo de Guzman y Canapit with intent to kill, committing the act with treachery and evident premeditation.
- Date of Incident: September 23, 2001
- Location: City of Manila, Philippines
- Plea: Appellant pleaded not guilty during his arraignment.
Key Facts of the Case
- Eyewitness Account: Jericho Capanas testified that he witnessed the appellant behaving unruly, breaking bottles, and attacking the victim.
- Incident Details:
- Around 3:30 AM on September 23, 2001, Capanas was awakened by noises outside.
- He observed the appellant kicking the victim's door and attacking Romeo de Guzman as he opened it.
- Appellant stabbed the victim in the chest and hacked his ear with a 20-inch bladed weapon.
- Capanas was close to the incident, less than an arm's length away.
- Aftermath: After the attack, Capanas called the police and assisted in transporting the victim to the hospital, where the victim later died from his injuries.
Evidence Presented
- Police Response: Officers found the appellant covered in blood with a bloodied weapon at the scene.
- Victim Identification: The victim identified the appellant as his attacker while receiving treatment.
- Medical Examination: Dr. Romeo Salen conducted the autopsy, confirming the cause of death as the stab wound to the chest.
Defense Testimony
- Appellant's Version: The appellant claimed he was engaged in a drinking spree with the victim and others before the attack.
- He